Last updated: 21/11/25

Operated by FPFY Ltd

1. Introduction
   This Privacy Policy explains how FPFY Ltd (“we”, “us”, “our”) collects, uses, stores and protects your personal information when you use Carnival Manor, our cross-platform game available via browser and mobile devices.
   We are committed to protecting your data and complying with the UK GDPR, EU GDPR, and applicable global privacy laws.
2. Who We Are
   FPFY Ltd
   11 Woodside Place
   Glasgow
   G3 7QF
   Scotland
   Contact email: support@fpfyltd.com
   Privacy team: Privacy Team
   We act as Data Controller for your information.
3. What Data We Collect
   We collect the following categories of personal data when you create an account or use Carnival Manor.
   3.1 Account Information- Email address
   – Username / display name- Encrypted password
   – Age or birthdate (for age verification)
   3.2 Gameplay & Usage Data
   – Gameplay actions and progress
   – In-game purchases and token use
   – Interaction logs
   – Behavioural analytics
   3.3 Device & Technical Data- IP address
   – Device type and operating system- Browser type (for web version)
   – Log files
   – Diagnostic information
   3.4 Cookies & Similar Technologies
   We use cookies for:
   – login/session management
   – analytics
   – fraud prevention
   – site performance
   3.5 Payment Data
   Payments are processed by third-party payment partners. We do not store bank, card, or account numbers. We receive only:
   – payment confirmation
   – amount
   – transaction status
4. How We Use Your Information
   We use your data for the following purposes.
   4.1 Providing and Managing Carnival Manor
   – Creating and maintaining your account
   – Delivering gameplay, tokens, and features
   – Saving progress and restoring accounts
   – Preventing fraud and abuse
   4.2 Payments
   – Processing purchases of tokens
   – Confirming transaction outcomes
   – Preventing unauthorised or fraudulent activity
   4.3 Analytics and Improvement
   – Understanding how players use the game
   – Improving features, stability, and performance
   – Identifying bugs and crashes
   4.4 Communications
   – Sending account-related messages
   – Customer support
   – Security or service notifications
   We do not send marketing emails without consent.
   4.5 Legal Compliance
   – Age verification
   – Responding to lawful requests from authorities
   – Record-keeping obligations
5. Legal Bases (UK/EU GDPR)
   We process your data under the following legal grounds:
   – Contract necessity – to provide the game and your account
   – Legitimate interests – security, fraud prevention, analytics
   – Legal obligation – tax, regulatory and anti-fraud requirements
   – Consent – for cookies and optional analytics (where required)
6. Third-Party Services We Use
   We share limited data with trusted providers to operate Carnival Manor.
   6.1 Hosting
   – Google Cloud
   6.2 Analytics
   – Google Analytics 4 (GA4)
   6.3 Error Monitoring
   – Sentry
   6.4 Marketing & Advertising
   – Meta (Facebook/Instagram) Ads
   (Only if you interact with an advert; we do not provide your email to Meta.)
   6.5 Email Service Provider
   – Microsoft (Microsoft 365 / Outlook / Exchange Online)
   These providers process data on our behalf under appropriate data protection agreements.
7. International Transfers
   Where data is transferred outside the UK/EU, we ensure safeguards such as:
   – UK/EU Standard Contractual Clauses
   – Adequacy decisions
   – Data processing agreements
8. Data Retention
   We retain your data only as long as necessary:
   – Account data: retained while your account is active
   – Gameplay data: retained for operation and backup integrity
   – Payment records: up to 6 years (legal requirement)
   – Analytics logs: up to 26 months
   – Cookies: per your browser settings
   You may request deletion at any time.
9. Your Rights (UK/EU GDPR)
   You have the right to:
   – Access your data
   – Correct inaccurate information
   – Request deletion (“Right to be forgotten”)
   – Restrict processing
   – Object to analytics processing
   – Port your data
   – Withdraw consent at any time
   – Lodge a complaint with your local data authority
   To exercise rights: support@fpfyltd.com
10. Protecting Your Data
    We apply industry-standard security measures:
    – Encrypted passwords
    – Secure encrypted communications (HTTPS/TLS)
    – Firewalls and DDoS protection
    – Access controls
    – Monitoring and intrusion detection
    – Regular security reviews
    No system is completely secure, but we take all reasonable measures to protect your information.
11. Children’s Privacy
    Carnival Manor is not intended for children under 13.
    We do not knowingly collect data from children under 13.
    If you believe a child has provided data, contact us to remove it.
12. Changes to This Policy
    We may update this Privacy Policy.
    The “Last Updated” date at the top reflects the current version.
13. Contact
    For privacy questions or data requests:
    support@fpfyltd.com
    Attn: Privacy Team, FPFY Ltd